ML20077J121
| ML20077J121 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/22/1983 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Sternberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20077J118 | List: |
| References | |
| ANPP-27334-BSK, NUDOCS 8308150240 | |
| Download: ML20077J121 (6) | |
Text
E E
~
093i,,,
Arizona Public Service Company
" 'l g, ['p P O BOX 21666
- PHOENIX Ant 2ONA 85036 OQ,E'<* b,.
~
July 22, 1983 ANPP-27334-BSK/ JAR U. S. Nuclear Regulatory Commission Region V Creekside Oaks Office Park 1450 Maria Lane - Suite 210 Walnut Creek, California 94596-5368 Attention:
Mr. D. M. Sternberg, Chief Reactor Projects Branch No. 1
Subject:
NRC Inspection Report of March 1 - April 30,1983 File: 83-019-026, D.4.33.2
Reference:
Letter ANPP-24182-BSK/ JAR dated June 27, 1983
Dear Sir:
This letter refers to the Inspection conducted by Mr. L. E.
Vorderbrueggen during March 1 - April 30,1983, as documented in your letter of May 25, 1983, of activities authorized by the Nuclear Regulatory Commission (NRC) Construction Permit No. CPPR-141,142, and 14 3.
During thic inspection, one item of noncompliance was identified. Our response to this item of noncompliance (Severity Level V - Supplement II) is presented in the enclosed Attachment A.
Very truly yours, I
Q.JLL ALUL P
4 E. E. Van Brunt, Jr.
APS Vice President Nuclear Projects Management ANPP Project Director EEVBJr/BSK:rb Attachment i
C308150240 830000 PDR ADOCK 05000528 O
f -
.Mr. D. M. Sternberg, Chief U. S. Nuclear Regulatory Conunission Page 2 cc:
T. G. Woods, Jr.
G. C. Andognini J. R. Bynum D. B. Fasnacht'-
A. C. Rogers W. E. Ide C. N. Russo G. E. Pankonin A. C. Gehr W. H. Wilson R. L. Patterson R. M. Grant D. R. Hawkinson P. P. Klute/D. D. Green j
4 5
h
..w
{
STATE OF ARIZONA
)) ss.
COUNTRY OF MARICOPA )
I, E. E. Van Brunt, Jr., represent that I am Vice President, Nuclear Projects of Arizona Public Service Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority so to do, that I have read such document and know. its contents, and that to the best of my knowledge and belief, the statements made therein are true.
c E. E. Van Brunt, Jr.
Sworn to before me this 8/f
' day of Q41 Oy 19 R$.
YLtA) f E]l.fAlk&b-JNotary Public j
My Commission Expires:
/lbteJO h
, 19 8 7 ~
g s.
k I
e ATTACHMENT A NOTICE OF VIOLATION Docket Nos. 50-528 and 50-529 Construction Permit Nos. CPPR-141 and CPPR-142 During an inspection on April 6,1983, and in accordance with the NRC Enforcement Policy, 10 CFR Part 2 Appendix C, 47 FR 9987 (March 9, 1982),
the following violation was identified:
10 CFR 50 Appendix B Criterion V states, in part:
" Activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings..."
Note 1.10 on Bechtel Drawing No. 13-E-ZAC-050, "Conducit and Tray Notes, Symbols and Details," specifies that "The maximum distance for unsupported cable (excluding manholes)in free air shall be 18 inches horizontally and 24 inches when more than one direction is involved unless raceway design drawings specify a larger unsupported span."
Note 23 on Bechtel Drawing No. 13-E-ZVG-007, Sheet 3, " Grounding Notes, Symbols and Details," states'"The ground fault current return path for all 4kV to 13.8kV circuits is provided by the shielding or
- the armor of the cable. The medium voltage power cable trays carrying these cables shall be grounded at.each end point."~
Section 9 of Bechtel Procedure WPP/QCI No. 251.0, " Raceway Installation" requires that "No raceways or raceway supports, or-parts thereof, shall be removed and/or reinstalled, relocated or modified without being documented.on an EE580 card.- The new card (s) for Quality Class
'Q' raceway shall be attached to the old card (s) by DCC personnel....."
Contrary to the above requirements, the power cables for both Containment Spray pump drive motors in Units 1 and 2 have unsupported lengths considerably in excess of 24 inches, the supporting cable trays are not grounded at both ends, and alterations were made to the raceway supports without documentation on new EE580 cards. (Control and Tracking. System
- Raceway. Installation Card).. The EE580 card documents the Quality _ Control acceptance inspection for the raceway installation / modification.
This is a Severity Level V violation (Supplement II) applicable to' Units 1 and 2.
l i
j e
1
r, p,,,,,
I-
~ ~
Attachment A Notice of Violation Page 2 L-APS Response
- Investigations. confirmed that:
Alterations were'made to these cable trays without documentation on a new EE580 card.
The Unit.1 cable trays for these cables were not grounded at both' ends.
Power cables for Unit I and 2' containment' spray pump drive' motors are not supported per existing design requirements.
1.
Corrective Steps Taken and Results Achieved Cable trays were-installed and inspected to Drawing 13-E-ZAC-003 in effect at the time (1979). Drawing Change Notice (DCN) No. 36 to Revision 13 of that drawing was issued to. cut the existing tray short and remove one tray support as the required cable bend radius could not be set.
The installed ground wire was cut at the.same. location as the tray'was cut.
It was connected approximately eight inches from the end of the tray.
In mid 1982, Non-Confonnance Reports (NCR's) E-A-2118 and E-A-2166 were' written identifying the missing documentation for this " Rework" of the tray. The NCR's were dispositioned "Use-As-Is" since the
~
configuration was considered adequate and a calculation would be done to justify its use.
However, a review of this design.by.the Resident Engineer and. Field Engineer indicated incorrect application of the-
" maple ~ blocks". As a result FCR's 42-444-E'and 42-456-E were issued to authorize and describe the maple block correction. Inspection of these cable support installations were made on the EE580 termination cards.
Between March 1 and April 30, 1983,. the NRC' identified the-cable support'which apparently. in NRC's opinion, still did not meet the
-drawing requirements and the ground wire which was not connected ~ to the end of the tray. The ground wire has been-properly connected to)
~
the end of the tray. EE580 Raceway Installation. Cards have now been -
completed to document the cable tray installation rework and connection:of the ground wire.
Even thoughithe installation appears to be in conformance with-drawing notes, APS Land Bechtel have determined' that a more conservative' approach,1 consistent with the Low Pressure Safety
- Injection (LPSI)'and'High' Pressure Safety Injection-(HPSI) pumps, is desirable. Therefore, Design Change Package (DCP) ISE, 2CE,-
y
'3CE-ZA-100 will be issued to' address a design modification.-
Additional"trayfsections will'be added to provide continuous support
~for the cable within 2 feet of the motor connection.
~
4 g
'w
/
f
' o.
'e.
l"
,.'.A*
O-Attachment A Notice of Violation Page 3 2.
Corrective Steps That Have Been Taken to Avoid Further Noncompliance Training is being conducted for all Unit Electrical Field Engineers and Electrical Quality Control Engineers. The instruction will cover the proper documentation required on EE580 cards for additions or deletions of cable, raceways or supports.
~
The cable 'aupport was not in conflict with drawing requirements.
Drawing Note 1.10 on 13-E-ZAC-050 allows deviation from the 24 and 18 inch requirements if specifically shown otherwise on drawings. The Field Change Requests (FCR's) 42-444-E and 42-456-E issued to show the-cable support design satisfied that requirement. Although a current review by Engineering has identified a requirement to add more support, the work done in 1979 was and is procedurally acceptable and additional corrective action is not required.
3.
Date When Full Compliance Was/Will Be Achieved Upon issuance of the approved DCP, the additional support work will be scheduled for completion af ter Hot ' Functional Testing and before Fuel Load.
Training 'for Unit 1 Electrical Field Engineers. was completed'on June 6,1983. Training for Electrical QCE's and Unit 2 and 3 Electrical Field Engineers was completed on July 15,.1983.
1
. )
r
--_-_-_-_--___a